Legal Opinion

Edell v. United States

United States Tax Court

Decided June 10, 1957No. Docket No. 882-RPublished

1. Held, (a) that contracts between petitioner and each of its several principals provided that petitioner would sell or attempt to sell products of a principal to a department of the Government, and would solicit, attempt to procure, and procure Government contracts for a principal; and (b) that under each of such contracts petitioner's compensation for its services was contingent upon the procurement of a Government contract; and that, therefore, (c) each of the contracts…

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1. Held, (a) that contracts between petitioner and each of its several principals provided that petitioner would sell or attempt to sell products of a principal to a department of the Government, and would solicit, attempt to procure, and procure Government contracts for a principal; and (b) that under each of such contracts petitioner's compensation for its services was contingent upon the procurement of a Government contract; and that, therefore, (c) each of the contracts between petitioner and its principals was a subcontract within the provisions of section 403 (a) (5) (b) (i) and (ii) of…

1Opinion of the Court

Harry Edell and Lewis H. Edell, a Copartnership, Doing Business as Harry Edell, Petitioner, v. United States of America, Respondent

Edell v. United States

Docket No. 882-R.

United States Tax Court

28 T.C. 601; 1957 U.S. Tax Ct. LEXIS 162;

June 10, 1957, Filed

1. Held, (a) that contracts between petitioner and each of its several principals provided that petitioner would sell or attempt to sell products of a principal to a department of the Government, and would solicit, attempt to procure, and procure Government contracts for a principal; and (b) that under each of such contracts petitioner's…

2Cases cited9 opinions

  1. Cohen v. Secretary of WarUnited States Tax Court · 1946
  2. Rosner v. War Contracts Price Adjustment BoardUnited States Tax Court · 1951
  3. Greaves v. War Contracts Price Adjustment BoardUnited States Tax Court · 1948
  4. Wolff & Phillips v. MacauleyUnited States Tax Court · 1947
  5. Bass v. StimsonUnited States Tax Court · 1953

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